Narrative Opinion Summary
The case of *Michael H. v. Gerald D.* involves a dispute over paternity rights and the application of California's legal presumption of legitimacy. Michael H., who had an affair with Carole D., sought to establish paternity of Victoria D., whom blood tests indicated was likely his biological child. However, Carole was married to Gerald D., who was listed as the father on the birth certificate. Michael initiated a paternity action, but the trial court granted Gerald summary judgment based on California Evidence Code § 621, which presumes that a child born to a married woman living with her husband is a child of the marriage. This presumption can only be contested under limited circumstances by the husband or wife. Michael and Victoria's motions for visitation were denied under California Civil Code § 4601, which limits visitation rights for putative fathers when the biological mother objects. Michael contested the decision, claiming violations of due process and equal protection, but these claims were rejected by the California Court of Appeal and the Supreme Court. The judgment emphasized the state's interest in preserving the integrity of the marital family unit and found that the presumption of legitimacy did not infringe upon constitutional rights, ultimately denying Michael's claim to parental rights.
Legal Issues Addressed
Constitutional Claims and Due Processsubscribe to see similar legal issues
Application: Michael's claims of due process violations were rejected, as the statute was held not to infringe upon his constitutional rights, emphasizing the state's interest in preserving the marital family unit.
Reasoning: The Supreme Court affirmed the judgment, with Justice Scalia stating that § 621 does not violate due process rights for men seeking to establish paternity when a child is born into an existing marriage.
Equal Protection and Legitimacysubscribe to see similar legal issues
Application: Victoria’s equal protection claim was rejected, as the statute was found to serve the legitimate purpose of preserving marital stability by restricting challenges to legitimacy.
Reasoning: Her assertion of equal protection violations, due to the inability to contest her legitimacy like her parents, is unfounded; the State's differentiation serves the legitimate purpose of preserving marital stability by limiting challenges to legitimacy to the husband or wife.
Presumption of Legitimacy under California Evidence Code § 621subscribe to see similar legal issues
Application: The court applies the presumption that a child born to a married woman living with her husband is presumed to be a child of the marriage, which can only be contested under specific circumstances by the husband or wife.
Reasoning: The trial court granted Gerald summary judgment based on California Evidence Code § 621, which presumes a child born to a married woman living with her husband is a child of the marriage, rebuttable only by the husband or wife under limited circumstances.
Visitation Rights under California Civil Code § 4601subscribe to see similar legal issues
Application: The court denied Michael and Victoria's motions for visitation, reinforcing the restriction on putative fathers' visitation rights when opposed by the biological mother.
Reasoning: The court denied Michael and Victoria’s motions for visitation, citing California Civil Code § 4601, which restricts visitation rights for putative fathers when the biological mother objects.